2022 (5) TMI 415

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....e Revenue : Shri Rajendra Kumar, CIT-DR. ORDER Per S.S. Godara, J.M. This Revenue's appeal for A.Y. 2016-17 arises from the Commissioner of Income Tax (Appeals) - 11, Hyderabad's, order dated 07.08.2020 in case No.10259/2019-20 involving proceedings u/s. 143(3) r.w.s 153A of the Income Tax Act, 1961 [in short, 'the Act']. Heard both the parties. Case file perused. 2. The Revenue raises the fo....

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....ugned assessment itself as not based on any incriminating material found or seized during the course of the search as under : 4. Learned CIT-DIR vehemently contended during the course of hearing that hon'ble jurisdictional high court's decision in Gopal Lal Bhadruka Vs. (2012) DCIT 346 ITR 106 supports the Revenue's case that a search assessment could very well be framed on altogether a new mater....